Transborder Data flows

 

  In Australia major documents for protecting privacy include the Commonwealth

  Principles for the  Fair Handling of Personal Information and the Guidelines for

  Federal & ACT Government Websites.

  Other Commonwealth laws contain privacy provisions relating to information about

  health insurance claims, data matching, information about old criminal convictions

  and personal information disclosed by telecommunications companies, video

  surveillance, telephone interception or 'bugging', and physical intrusion into

  private spaces.

 

  The new regime aims to:

  • recognise that many organisations now operate across national

      boundaries

  • ensure that organisations don't avoid their obligations by simply

       moving personal information overseas

  • remove potential barriers to international trade

  Overseas activities

  The Act will apply to the overseas activities of Australian and foreign

  organisations, in the context of personal information of an Australian

  citizen or resident, if there's a link with Australia. The organisation has a

  link with Australia if:

  • there's an organisational link - for example, the organisation is

       incorporated in Australia, or a trust created in Australia.

  • the organisation carries on business in Australia or an external

      Territory; or

  • the organisation collected or held personal information in Australia

      or an external territory, either before or at the time of the activity.

  Overseas activity required by law

  If an organisation's overseas activity is required by the law of a foreign

  country,then it doesn't interfere with the privacy of an individual.

 

  Sending personal information out of Australia

 

  There are currently no legislative prohibitions on organisations transferring

  personal information from Australia to other countries. From 21 December 2001,

  organisations will have to comply with the NPP 9, which relates to the transborder

  flow of data. It prohibits the transfer of personal information to other countries

  unless certain criteria are met. It's based on the restrictions on international

  transfers of personal information set out in the European Directive 95/46.

  NPP 9 does not prevent the transfer of personal information out of Australia by

  an organisation to another part of that organisation, or to the individual concerned.

  An organisation may transfer personal information overseas provided that

  one of the following conditions is satisfied:

 

  the organisation reasonably believes a law, binding scheme or contract

  applies at the destination which effectively delivers privacy standards

  substantially similar to the NPPs

 

  the individual consents to the transfer;

 

  the transfer is for the benefit of the individual and it's impracticable to obtain

  consent, but it's likely consent would be given;

 

  the transfer is required by a contract between the individual and the organization

  , or a contract between the organisation and a third party in the interests of the

  individual; or the organisation has taken reasonable steps to ensure the

  information won't be held, used or disclosed by its recipient inconsistently

  with the NPPs.

 

  It is important to note that NPP 9 will apply to information collected before

  21 December 2001, as well as information collected after that date. This

  means that after 21 December 2001, an organisation must not transfer personal

  information out of Australia unless one of the criteria in NPP 9 is met,

  regardless of when it was collected.

 

  Sending personal information into Australia

 

  The European Union has imposed a minimum standard for data handling

  practices on its members (EU Directive on the Protection of Individuals

  with regard to the Processing of Personal Data and the Free Movement

  of such data 95/46). It requires data transferred outside the EU to be handled

  in a specific manner.

  Australia's new privacy regime aims - among other things - to bring Australia

  in line with this minimum standard. 

  Under EU Privacy Legislation, the EU can assess whether specific data

  regimes are "adequate". If they are, organisations coming under the EU

  regime can participate in trade involving personal information with the EU

  member states with no further privacy safeguards. The EU has begun to

  asses the new Australian regime to see whether it meets the required

  standard

 

  Latest developments

 

  An EU working party has released its opinion on whether Australia’s new

  privacy regime meets the "adequacy" test: the outcome is more work needs

  to be done.

  Until the new privacy regime is approved by the EU, you may be asked to

  provide appropriate privacy protection to the sender if you want to receive

  information from outside Australia

  Other Commonwealth laws contain privacy provisions relating to information

  about health insurance claims, data matching, information about old criminal

  convictions and personal information disclosed by telecommunications

  companies, video surveillance, telephone interception or 'bugging', and

  physical intrusion into private spaces.